Frequently Asked Questions

Further Information about the Lawsuit

1. Why was the Notice issued?

The Court overseeing the Lawsuit authorized the Notice to advise Settlement Class Members about the proposed Settlement that will affect their legal rights. You received the Notice because you may be a member of the Settlement Class eligible to receive benefits from a proposed settlement in the Lawsuit. The Notice explains certain legal rights and options you have in connection with that Settlement.

2. What is this lawsuit about?

The Lawsuit is a proposed class-action lawsuit against Concord brought on behalf of all persons who were sent written notice by Concord that their Personal Information was potentially compromised as a result of the Cyberattack.

3. What is the Lawsuit a class action?

In a class action, one or more representative plaintiffs bring a lawsuit for others who are alleged to have similar claims. Together, these people are the “class” and each individually is a “class member.” There is one Plaintiff (or Representative Plaintiff) in this case: Karen Edwards.

4. Why is there a Settlement?

The Plaintiff in the Lawsuit, through her attorneys (“Settlement Class Counsel”), investigated the facts and law relating to the issues in the Lawsuit. The Plaintiff and Settlement Class Counsel believe that the settlement is fair, reasonable, and adequate and will provide substantial benefits to the Settlement Class. The Court has not decided whether the Plaintiff’s claims or Concord’s defenses have any merit, and it will not do so if the proposed Settlement is approved. By agreeing to settle, both sides avoid the cost and risk of a trial, and people who submit valid claims will receive benefits from the Settlement. The Settlement does not mean that Concord did anything wrong, or that the Plaintiff and/or the Settlement Class would, or would not, win the case if it were to go to trial.

Terms of the Proposed Settlement

5. Who is in the Settlement Class?

The Settlement Class is defined as all individuals who were sent notice related to the data breach disclosed by Concord on or about February 1, 2024.

Excluded from the Settlement Class are: (a) Concord’s officers and directors; (b) any entity in which Concord has a controlling interest; and (c) the affiliates, legal representatives, attorneys, successors, heirs, and assigns of Concord. Also excluded from the Settlement Classes are members of the judiciary to whom this case is assigned, their families and members of their staff.

6. What are the Settlement Benefits?

Settlement Class Members who submit a valid Settlement Class Claim Form may be entitled to receive the following benefits:

1. Ordinary Losses up to $700, which includes the following:

1. Out-of-pocket expenses incurred as a result of the Cyberattack, including bank fees, long distance phone charges, cell phone charges (only if charged by the minute), data charges (only if charged based on the amount of data used), postage, or gasoline for local travel; and

2. Fees for credit reports, credit monitoring, or other identity theft insurance product purchased on or after November 14, 2022, through March 3, 2025.

2. Extraordinary Losses up to $7,500, which includes compensation for proven monetary loss, professional fees including attorneys’ fees, accountants’ fees, and fees for credit repair services incurred as a result of the Cyberattack.

3. Lost Time spent dealing with the Cyberattack will be compensated at a rate of $20 per hour for up to five hours, if at least one full hour was spent dealing with the Cyberattack. Claimants must attest to the accuracy of any request for compensation for lost time but are not required to submit supporting documentation.

Compensation for the above losses (except lost time) will only be paid if:

• The loss is an actual, documented, and unreimbursed monetary loss;

• The loss was more likely than not caused by the Cyberattack;

• The loss occurred between November 14, 2022, and July 3, 2025;

• You made reasonable efforts to avoid, or seek reimbursement for, the loss, including but not limited to exhaustion of all available credit monitoring insurance and identity theft insurance;

• Documentation of the claimed losses is not “self-prepared.” Self-prepared documents, such as handwritten receipts, are, by themselves, insufficient to receive reimbursement. Claimants must submit reasonable documentation in support of their claim for out-of-pocket losses, to be evaluated by the Claims Administrator.

No payment shall be made for emotional distress, personal/bodily injury, or punitive damages.

4. Cash Payment Settlement Class Members who submit a valid and timely claim may also elect to receive a one-time payment of $70 without the need to document losses or attest to time spent as a result of the Cyberattack.

7. What claims are Settlement Class Members giving up under the Settlement?

Settlement Class Members who do not validly exclude themselves from the Settlement will be bound by the Settlement Agreement and Release (“Settlement Agreement”), and any final judgment entered by the Court, and will give up their right to sue the Released Parties for the claims being resolved by the Settlement.

The claims that are being released and the persons and entities being released from those claims are described in the Settlement Agreement. To view the Settlement Agreement, please click here.

Your Options as a Settlement Class Member

8. If I am a Settlement Class Member, what options do I have?

If you are a Settlement Class Member, you do not have to do anything to remain in the Settlement. However, if you want to request compensation for unreimbursed expenses and losses or the alternative cash payment, you must complete and submit a Settlement Class Claim Form postmarked or submitted online by July 3, 2025. You may submit a Settlement Class Claim Form online here.

If you do not want to give up your right to sue the Released Parties about the Cyberattack or the issues raised in this case, you must exclude yourself (or “opt out”) from the Settlement Class. See Question 12 for instructions on how to exclude yourself.

If you object to the settlement, you must remain a Settlement Class (i.e., you may not also exclude yourself from the Settlement Class/Subclass by opting out) and file a written objection in this case with the Court. (See Question 15.) If you object, you must still submit a claim if you want compensation for unreimbursed losses or identity theft protection and credit monitoring services.

9. What happens if I do nothing?

If you do nothing, you will get no benefit from this Settlement. Unless you exclude yourself, after the Settlement is granted final approval and the judgment becomes final, you will be bound by the judgment and you will never be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against the Released Parties related to the claims released by the Settlement.

10. How do I submit a claim?

You may complete the Settlement Class Claim Form online here or download the paper Settlement Class Claim Form by clicking here. If you choose to complete a paper Settlement Class Claim Form, you may either submit the completed and signed Settlement Class Claim Form via email (info@ConcordMusicGroupDataSettlement.com) or mail them to:

Concord Music Group, Inc.
Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799

11. Who decides my Settlement claim and how do they do it?

The Claims Administrator will initially decide whether a Settlement Class Claim Form is complete and valid and includes all required documentation. The Claims Administrator may require additional information from any claimant. Failure to timely provide all required information will invalidate a claim and it will not be paid.

12. How do I exclude myself from the Settlement?

You must make a signed written request that (i) clearly states that you wish to exclude yourself from the Settlement Class in the Lawsuit, and (ii) include your name, address, and phone number. You must send your request by June 3, 2025 to this address:

Concord Music Group, Inc.
Claims Administrator
Attn: Exclusions
P.O. Box 25226
Santa Ana, CA 92799

13. If I exclude myself, can I receive a benefit from this Settlement?

No. If you exclude yourself, you will not be entitled to any Settlement benefits. However, you will also not be bound by any judgment in the Lawsuit.

14. If I do not exclude myself, can I sue the Released Parties for the Cyberattack later?

No. Unless you exclude yourself, you give up any right to sue the Released Parties for the claims that this Settlement resolves. You must exclude yourself from the Settlement Class to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. If you exclude yourself, do not submit a Settlement Class Claim Form requesting a benefit from this Settlement.

15. How do I object to the settlement?

All Settlement Class Members who do not request exclusion from the Settlement Class have the right to object to the Settlement or any part of it. You can ask the Court to deny approval of the Settlement by filing an objection. You can’t ask the Court to order a different settlement; the Court can only approve or reject the Settlement. If the Court denies approval, no settlement benefits will be sent out and the lawsuit will continue.

Any objection to the proposed Settlement must be in writing and it and any supporting papers must be filed with the Court and mailed to Class Counsel and Concord Music Group, Inc.’s Counsel.

Objections must be filed or postmarked no later than June 3, 2025.

No Settlement Class Member will be heard and no papers submitted by any Settlement Class Member will be considered unless, no later than 30 days before the initial scheduled Final Approval Hearing (“Objection Deadline”), the Settlement Class Member files with the Court and mails to Class Counsel and Defendant’s counsel written objections that include: (a) the title of the case; (b) the objector’s full name, current address, telephone number, and email address; (c) the Settlement Class Member’s original signature; (d) all legal and factual bases for any objection; (e) copies of any documents that the objector wants the Court to consider; (e) all counsel representing the Settlement Class Member, if any; (f) the signature of the Settlement Class Member’s duly authorized attorney or other duly authorized representative, along with documentation setting forth such representation; and (g) a list, including case name, court, and docket number, of all other cases in which the objector and/or the objector’s counsel has filed an objection to any proposed class action settlement in the past five years.

Should the objector wish to appear at the Final Approval Hearing, he or she must so state, and must identify any documents or witnesses the Settlement Class Member intends to call on his or her behalf, and the attorney(s) representing the objecting Settlement Class Member who will appear at the Final Approval Hearing and include the attorney(s) name, address, phone number, email address, state bar(s) to which counsel is admitted, as well as associated bar number

If you fail to object in this manner, you will be deemed to have waived and forfeited any and all rights you may have to appear separately and/or to object to the Settlement Agreement, and you shall be bound by all the terms of the Settlement Agreement and by all proceedings, orders, and judgments in the Lawsuit. The exclusive means for any challenge to the Settlement Agreement shall be through the provisions set forth in this paragraph. Without limiting the foregoing, any challenge to the Settlement Agreement, the Final Judgment and Order approving this Settlement Agreement, or the judgment to be entered upon final approval shall be pursuant to appeal under the Tennessee Rules of Appellate Procedure and not through a collateral attack.

Court Approval of the Settlement

16. How, when, and where will the Court decide whether to approve the Settlement?

The Court will hold a Final Approval Hearing to decide whether to approve the Settlement. That hearing is scheduled for July 22, 2025, at 9:00 a.m., at the Circuit Court for Davidson County, Tennessee at the Nashville Courthouse. At the Final Approval Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are timely objections, the Court will consider them and will listen to people who have properly requested to speak at the hearing. The Court may also consider Plaintiff’s request for attorneys’ fees and costs, and Plaintiff’s request for a service award for the Representative Plaintiff. During or after the hearing, the Court will decide whether to approve the Settlement.

It is possible the Court could reschedule the hearing to a different date or time without notice, so it is a good idea before the hearing to reference the Important Dates and confirm the schedule if you wish to attend.

17. Do I have to attend the hearing?

No. You do not need to attend the hearing unless you object to the Settlement and wish to appear in person. It is not necessary to appear in person to make an objection; the Court will consider any written objections properly submitted according to the instructions in Question 15. You or your own lawyer are welcome to attend the hearing at your expense but are not required to do so.

18. What happens if the Court approves the Settlement?

If the Court approves the Settlement, the Settlement will become effective, and distributions for valid and approved claims will begin 30 days after the Effective Date. In the event there are objections to the Settlement or an appeal, it is possible the Settlement could be disapproved. We do not know how long this process may take.

19. What happens if the Court does not approve the Settlement?

If the Court does not approve the Settlement, there will be no Settlement benefits available to Settlement Class Members, Class Counsel, or the Plaintiffs, and the case will proceed as if no Settlement had been attempted.

If I Do Nothing

20. Who represents the Settlement Class?

The Court has appointed the following Class Counsel to represent the Settlement Class Members in the Lawsuit:

J. Gerard Stranch, IV
STRANCH, JENNINGS & GARVEY, PLLC
223 Rosa L. Parks Ave.
Suite 200
Nashville, TN 37203

Settlement Class Members will not be charged for the services of Class Counsel; Class Counsel will be paid by Concord, subject to Court approval. However, you may hire your own attorney at your own expense to advise you in this matter or represent you in making an objection or appearing at the final settlement approval hearing.

21. How will the lawyers for the Settlement Class be paid?

Plaintiff will seek an order from the Court requesting that attorneys’ fees be awarded to Class Counsel in the amount of up to $200,000 inclusive of any costs and expenses of the Lawsuit (the “Class Counsel Payment”).

Plaintiff will also seek an order from the Court requesting that a Service Award in the amount of up to $2,500 be awarded to him for his time and effort expended on behalf of the Settlement Class in the Lawsuit.

If the Court awards the Class Counsel Payment or the Service Award described above, the Court’s award(s) will not affect any benefits provided to Settlement Class Members, or Plaintiff.

22. Who represents Concord in the Lawsuit?

Concord is represented by the following lawyer:

Mark Steiner
MCDONALD HOPKINS LLC
39533 Woodward Ave.
Suite 318
Bloomfield Hills, MI 48304

For Further Information

23. What if I want further information or have questions?

For additional information and important documents, please visit the Important Documents page. You may also contact the Claims Administrator by mail, email, or phone:

Concord Music Group, Inc.
Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
info@ConcordMusicGroupDataSettlement.com
1 (833) 296-0829

PLEASE DO NOT CONTACT THE COURT OR CONCORD MUSIC GROUP, INC.’S COUNSEL FOR INFORMATION REGARDING THIS SETTLEMENT.